Montenegro Should Reopen CIP Argues EU-Accession Negotiations Coordinator

In an interview with Bankar, Bojan Bugarin, a former coordinator of Montenegro’s visa liberalization process with the EU, strongly advocates for relaunching Montenegro’s Citizenship by Investment Program (CIP) – with appropriate adjustments.

He argues that processing the remaining applications could inject over €1 billion into the country’s economy.

The government launched the initial CIP in 2019, capping it at 2,000 applications for citizenship. However, the government has only approved 850 applications, according to Bugarin.

He emphasizes that this leaves room for more than 1,000 additional applications that Montenegro can approve through a renewed program.

He reveals that before the program’s implementation, the European Commission and then-Chancellor Angela Merkel gave Montenegro the green light to approve 2,000 applications.

The Commission determined that this number did not pose “significant risks and challenges to the interests of the EU and its member states.”

Program impact and potential benefits

Despite its early conclusion, Bugarin highlights the program’s substantial impact:

• Authorities had approved 850 applications as of September 2024.
• Special funds and the Innovation Fund received €84.5 million.
• The state budget gained €43.5 million.
• Investors poured €243.7 million into development projects, including luxury hotels.

Bugarin estimates the CIP’s total contribution to Montenegro’s economy was €500 million. He says that “ordinary citizens could feel the benefits through economic growth, job opportunities, better social services, improved infrastructure, and education.”

He outlines several benefits of relaunching the program:

• Strengthened fiscal stability and economic growth.
• Increased inflow of investments.
• Enhanced competitiveness and economic sustainability.
• Greater autonomy and reduced dependence on foreign loans.
• Improved ability to direct national resources where most needed.

Bugarin, however, acknowledges potential risks, primarily political concerns over how the European Commission and member states would react to the program’s relaunch and what repercussions it could have on the EU negotiation process.

To mitigate these risks, he suggests implementing “proper international due diligence checks on applicants, carried out by reputable European agencies in this field, and potentially involving specialized EU agencies.”

Bugarin believes this approach would prevent potential misuse and “ease the fears and concerns” of the European Commission and member states that anyone would “use the program for abuse or money laundering.”

“A sovereign right” to run a CIP

Addressing concerns about the program’s potential impact on Montenegro’s EU negotiations, Bugarin notes that the European Commission closely scrutinized the previous program despite initial approval.

He attributes this scrutiny to “a lack of proper, professional communication” between successive Montenegrin governments and the European Commission.

Bugarin reveals that inexperienced government actors and lack of transparency in implementation led to “certain doubts” and “concerns and suspicions” within the European Commission. This resulted in the Commission perceiving the program as a “potential money laundering scheme.”

To support his argument for relaunching the program, Bugarin draws comparisons with other European practices:

• European countries, mostly Malta, process only a few hundred investment citizenship applications annually, conducting thorough international background checks.
• Eurostat reports EU countries grant over 700,000 citizenships yearly based on naturalization and ancestry, often without detailed background checks.
• The EU accepts around 600,000 undocumented migrants annually, plus millions of Ukrainian refugees.

“It is therefore absurd to think and believe that a few hundred citizenships granted by Montenegro under its program would pose a security threat to the EU or open doors to criminal elements in the EU,” Bugarin argues.

He points to Malta’s ongoing legal battle with the EU over its citizenship program as a potential precedent. Bugarin notes that Malta’s program has raised billions of euros for the local economy over the past ten years. Maltese politicians recognize its crucial importance, firmly defending their sovereign rights.

Malta has engaged top lawyers and European experts in this field and “expects to win its case before the Court of Justice of the European Union.”

Bugarin’s personal experiences with program applicants have been “exclusively positive.” He describes them as “very high-quality and successful professionals” who have substantially invested in Montenegro.

He says the Montenegrin program attracted top-tier global entrepreneurs and investors, including “prominent figures from the tech industry, including top management from Google, major cosmetic and fashion industry chains, bankers, and doctors working in the world’s most prestigious clinics.”

“The quality of applicants best illustrates the program’s success,” Bugarin states. “Any country in the world would wish for such individuals as its citizens, and that is the essence of such programs: to bring in valuable individuals who will contribute to and enhance the country’s development in the long term.”

While acknowledging that Montenegro must meet its EU accession obligations, Bugarin maintains that decisions on citizenship remain a sovereign right under both international and EU law.

He believes a well-managed CIP could coexist with Montenegro’s EU aspirations, potentially even accelerating development to meet accession criteria.

“Montenegro’s path to the EU remains stable,” Bugarin asserts. “However, a country has the sovereign right to decide on all matters regarding its citizenship—both under international law and EU law. The EU’s rule of law principle itself dictates that each country makes this decision independently.”

Bugarin concludes by emphasizing the need to convince European partners that the program is not a “scheme for money laundering” or attracting “suspicious capital” but a genuine opportunity for Montenegro’s development.

He advocates for intensive cooperation with the European Commission on international checks of all future applicants to ensure only credible investors participate in the program.